On March 8, ARSA sent a letter to the FAA requesting that the agency clarify (or, re-clarify) that fabrication of a part is not maintenance.

ARSA’s appeal was driven by several members who recently contacted the association with issues regarding the manufacture of detail parts by maintenance personnel and local inspector interpretations of that practice. With the issue was clearly addressed by a previous legal interpretation from the FAA Office of Chief Counsel and is supported by existing agency guidance, it became apparent that the confusion resulted from individual FAA inspector misunderstandings.

The inspector misinterpretations resulted in claims that a repair station was contracting maintenance functions without FAA approval and not performing maintenance according to regulations. By wrongly categorizing fabrication as maintenance, the FAA was shifting industry focus away from proper execution of the task.

As a result, ARSA asked the FAA to ensure that its front-line inspectors were fully aware of the current policy regarding part fabrication by maintenance providers.

On March 22, the FAA responded, agreeing with the association. “Your understanding on the act of fabrication is correct. It is not considered maintenance,” said Manager Carol E. Giles of the FAA’s Aircraft Maintenance Division.

Giles further advised ARSA that on April 16, 2011, the second compliance date for the revised Title 14 CFR part 21 will become effective and it specifically includes a section addressing part fabrication by an appropriately rated certificate holder.

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